State v. Messenger

Summary

The Ohio Supreme Court affirmed the Court of Appeals, holding that the defendant’s burden of production on a self‑defense claim is reviewed for sufficiency of the evidence, the state’s burden of persuasion to disprove self‑defense is reviewed for manifest weight, and the 2018 amendment to R.C. 2901.05 did not eliminate the defendant’s production burden. The court explained the statutory language and constitutional principles governing affirmative defenses.